Yegiazaryan v. Smagin
In brief
A foreign plaintiff's injury can count as domestic under civil RICO when the full circumstances show it arose in the United States.
- Where it stands
- Decided
Decided 6-3 · June 22, 2023 · Opinion by Justice Sotomayor
- What it’s about
- Vitaly Smagin, a Russian citizen, sued another Russian citizen residing in California under the RICO Act for attempting to evade a U.S. court judgment.
- Who it affects
- Foreign plaintiffs may be able to use civil RICO when alleged efforts to evade a judgment occur in the United States. For example, a judgment owner can pursue a claim if alleged racketeering activity in the United States caused the injury.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that a foreign plaintiff can file a private civil RICO suit if the circumstances show the injury arose in the United States.
The decision rejected a single location-based rule for deciding whether an injury involving foreign parties and intangible property occurred in the United States.
Question presented
Whether a foreign plaintiff states a “domestic injury” for purposes of the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. § 1964(c), when the plaintiff owns a foreign judgment that the defendant has allegedly sought to evade through racketeering activity in the United States.
What the Court decided
Holding
A plaintiff alleges a domestic injury for purposes of §1964(c) when the circumstances surrounding the injury indicate it arose in the United States. 37 F. 4th 562, affirmed and remanded.
- Result
- Affirmed
The vote
From the opinions
““A plaintiff alleges a domestic injury” when the surrounding circumstances indicate that it arose in the United States.”
What's next
The case returns to the lower courts, which must apply the Supreme Court's circumstances-based test. Parties in similar cases can argue that the location and nature of the alleged conduct show a domestic injury.
Documents
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
AI analysis generated: Decision Record
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AI analysis generated: Case Briefing
Opinion added: Yegiazaryan
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Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Yegiazaryan v. Smagin?
- The Court said a foreign plaintiff can allege a domestic injury under civil RICO when the circumstances show the injury arose in the United States.
- Who is affected by the Yegiazaryan v. Smagin decision?
- Foreign judgment owners may use civil RICO if alleged U.S.-based racketeering caused their injury. Courts must assess the full circumstances rather than one location alone.
- What happens next in Yegiazaryan v. Smagin?
- The case returns to the lower courts. They will apply the Supreme Court's circumstances-based test in further proceedings.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.